The Centers for Medicare & Medicaid Services is on track to deploy IT systems that can manage data submissions for the quality payment program, according to the Department of Health and Human Services’ Office of Inspector General.
But technical assistance for physicians who will submit quality data is still lacking, the agency said in a report (PDF) released on Thursday. And without a comprehensive integrity plan, the program could be vulnerable to fraud and abuse.
The update comes a year after the OIG identified IT systems development as a critical factor in ensuring QPP success, a physician payment program created through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) which requires value-based payment adjustments beginning in 2019. Since that report, OIG says CMS has made “significant progress developing the IT systems necessary to support the QPP,” including new functionality to the public website and new tools to determine clinician eligibility.
CMS has also tested, but not yet fully deployed, applications designed to streamline the submission process and is in the process of authenticating accounts and fine-tuning eligibility determinations.
But that technical infrastructure will be diminished if clinicians participating in QPP don’t have a sufficient understanding of the new program and how to report data. Small practices in rural medically underserved areas of the country are particularly vulnerable, according to the OIG.
The agency also raised concerns about a feature of the IT system that provides immediate feedback to clinicians about whether they have earned the maximum points available. Designed to allow clinicians to correct errors, the OIG said the functions allow “a user to ‘game’ the submission system” pointing specifically to a checklist in which clinicians must certify their EHR use.
“Although users may resubmit their data to obtain the highest score to which they are lawfully entitled, this same resubmission process could be abused if users submit inaccurate data solely for the purpose of obtaining the maximum possible points," the agency stated in its report.